Evelyn Partners Asset Management Limited

EVELYN PARTNERS ASSET MANAGEMENT LIMITED 1. Cover Page EVELYN PARTNERS ASSET MANAGEMENT LIMITED 45 Gresham Street London, EC2V 7BG United Kingdom https://usa.evelyn.com/evelyn-partners-usa/ Part 2A of Form ADV: Firm Brochure March 31, 2026 This Firm Brochure (the “Brochure”) provides information about the qualifications and business practices of Evelyn Partners Asset Management Limited (“Evelyn Partners”, “EPAM” or the “Firm”). If you have any questions about the contents of this brochure, please contact by telephone at +44 203 8186930 or by email at us.services@evelyn.com.The information in this Brochure has not been approved or verified by the United States Securities & Exchange Commission (the “SEC”) or by any state securities authority. Additional information about EPAM also is available on the SEC’s website at www.adviserinfo.sec.gov. Page 1  EVELYN PARTNERS ASSET MANAGEMENT LIMITED 2. Material changes The purpose of this page is to inform you of any material changes from the previous version of this Brochure, filed March28, 2025. In November 2025, Item 10 of the Brochure was updated to reflect the removal of Evelyn Partners Fund Solutions Limited, Evelyn Partners LLP and Evelyn Partners Corporate Finance Limited, as the entities were sold and were no longer part of Evelyn Partners Group Limited (the “Group”). The November 2025 update of the Brochure also included information on staff changes including the appointment of a new Group Chief Financial Officer (“CFO”), following the departure of the outgoing Group Chief Financial Officer and their interim replacement. In addition, changes to the Remuneration Committee and appointment of a new Independent Non-Executive Director, following the departure of an outgoing Independent Non-Executive Director, were noted. In this Brochure, Schedule D has been updated to notify that Symmetry Joint Venture L.P., Overseas Trust and Pension Limited and Violin Debtco Guernsey Limited, amongst others, have entered into a Sale and Purchase Agreement, dated as of February 9, 2026, pursuant to which National Westminster Bank PLC (“Purchaser”) will acquire all or substantially all of the equity interests in Symmetry Topco Guernsey Limited (“STGL”), the parent company of Evelyn Partners Asset Management Limited (“EPAM”) (the “Transaction”). This is subject to UK Regulatory Approval. Item 4 references the extension of the Firm’s advisory activity in respect to financial planning services provided to a limited number of clients. Item 10 notes that Evelyn Partners Financial Services Limited has been sold with a targeted completion date of 1 April 2026. In addition, Item 10 also highlights that Evelyn Partners Financial Planning Limited (“EPFP”), which is not registered with the SEC as an investment adviser, has entered, or expects in the near future to enter into a “participating affiliate” agreement with EPAM whereby certain of EPFP’s personnel provide various investment advisory services to EPAM for use with its U.S. clients. There are no other material changes to note. We will review and update our brochure at least annually to make sure that it remains current. Page 2  EVELYN PARTNERS ASSET MANAGEMENT LIMITED 3. Table of Contents 1 1. Cover Page 2 2. Material Changes 3 3. Table of Contents 4 4. Advisory Business 4 5. Fees and Compensation 6 6. Performance based fees and side-by-side management 6 7. Types of Clients 6 8. Methods of analysis, investment strategies, and risk of loss 8 9. Disciplinary information 8 10. Other Financial Industry activities and affiliations 10 11. Code of ethics, participation or interest in client transactions and personal trading 11 12. Brokerage practices 11 13. Review of Accounts 11 14. Client Referrals and Other Compensation 11 15. Custody 12 16. Investment discretion 12 17. Voting Client securities 12 18. Financial information Page 3  4. Advisory business Evelyn Partners Asset Management Limited (“We”, “Us”, “Evelyn Partners”, “EPAM” or the “Firm”) is a United Kingdom (“UK”) based wealth Management Company which is a wholly owned subsidiary of Evelyn Partners Group Limited. The ultimate parent companies are Platinum L.P. Guernsey Limited and Whitman Limited Partner L.P. Evelyn Partners provides discretionary investment management services across a broad range of client account types, including (where eligible) investment portfolios, retirement accounts, personal pensions, trust and charity accounts and insurance company accounts. The Discretionary Portfolio Service (DPS) allows for the purchase and sale of specific securities and can, in some circumstances, allow for you to impose certain restrictions; meaning we will not purchase any securities which, for any reason, you may not be comfortable holding. The Firm also offers financial planning services to clients. In addition, the Firm provides discretionary management services in respect of a private fund, Evelyn Partners Global IDF L.P (“IDF”). As of 31 December 2025, the Firm managed approximately $1,059,392,636 in regulatory assets under management, with all managed on a discretionary basis and does not have any regulatory assets under management attributed to non-discretionary investment advisory services. In this document, “Client” means all clients of the Firm and consists of any entity or natural person to which the Firm provides investment advisory or management services, including each private fund and all managed account clients. 5. Fees and compensation Our charges are levied based on the value of the assets that our clients entrust us to manage. We charge our clients on a tiered basis which means that our percentage investment management fee will decrease as your assets increase. There are three principal sources of cost to clients resulting from investment management: 1. Our fee for managing the portfolio 2. The underlying investment management fees of any funds that we choose to hold 3. Custodian charges from Pershing Advisor Solutions LLC (“Pershing”). The above 1-3 are further outlined below. a. Evelyn Partners Management Fee The annual fee for our investment management services would be a tiered fee as below: Charging Structure Portfolio Size Investment Management Fee (% of assets) (Per Annum) First $325,000 1.05% Next $325,000 0.90% Next $2,600,000 0.70% Above $3,250,000 0.40% Page 4  A minimum Investment Management fee of $1,125 plus VAT (where applicable) per quarter will apply. Fees will be calculated for an initial period and then debited at calendar quarter ends in arrears. Fees are calculated daily using the annual fee rate and closing quarter end value annual fee rate. Where this calculation results in a fee amount below the minimum, the minimum will be charged instead. The fee is debited from cash held within the portfolio and paid to Evelyn Partners. Market movements along with contributions and withdrawals will affect the value of your assets, therefore, fees charged will move up and down. We do not charge any fees for transactions, however there are transaction fees levied by our custodian Pershing (see “Custodian Charges” below). EPAM also uses other custodians. Further details, including fees, are available on request. Regarding Global IDF, the fee is 1.25% of [assets under management], deducted after expenses, accrued monthly and paid quarterly in arrears. b. Underlying Fund Costs When investing in Collective Investment Schemes (Funds), there are ongoing costs associated with running such Funds. These will include the EPAM’s annual management charge and other expenses, and these are deducted by EPAM from such Fund. These charges are known as the Ongoing Charges Figure or OCF. A Fund’s transaction costs are not included in the OCF and are charged to the Fund. The OCF will vary between funds but will normally be around 0.35% for equity funds and 0.35% for tracker funds. Custodian Charges The main costs from Pershing are shown below: $10 flat ticket charge up to 3,000 shares. Each additional share over 3,000 • US Stocks will be charged at $0.01 per share. US Mutual Funds $25 per transaction • 25 basis points subject to a $25 minimum charge plus a foreign settlement • Non-US Stocks fee* Cash transfers $20 for transferring money out of your account • Legal stock transfers $40 per transfer • Account termination $100 per account • *Please note that for non-US stocks, we will aim to buy cost-effective, US-listed versions of these companies where possible, such as American Depositary Receipts (“ADRs”). These are securities that trade in U.S. financial markets that represent the securities of non-U.S. companies. The costs would therefore be associated with US stocks as opposed to the higher costs incurred by buying the non-U.S. stocks directly in foreign markets. c. Fund Expenses For IDF, each portfolio shall bear its own operating costs and expenses, including, but not limited to, administrative, legal and audit fees directly related to the operations of the portfolio, expenses related to the investment of an asset, such as brokerage commissions, custodial charges, and clearing fees, fees paid to other service providers, and all other expenses associated with the operation of the relevant portfolio. Operating expenses, as with other expenses, shall be allocated to and charged against the capital accounts of limited partners investing in such portfolio in proportion to their capital account balances in the portfolio. 6. Performance-based fees and side-by-side management Evelyn Partners does not charge performance-based fees. Page 5  7. Types of clients Evelyn Partners can generally provide investment management services to high-net-worth individuals and families, companies, charities, trusts, private funds and financial intermediaries on a discretionary basis. The initial commitment for IDF is $100,000, and for other clients our minimum account size is £350,000 or USD equivalent. 8. Methods of analysis, investment strategies and risk of loss Our investment process is based on the principle that asset allocation will be the primary determinant of long- term investment performance. Each portfolio is run within a specific risk profile to which an asset allocation will be assigned with the goal of maintaining the appropriate long-term risk reward parameters that have been agreed with the client. The appropriate asset allocation at any given time will be determined by the quantitative and qualitative output of our investment process, considering such factors as: Medium and Long-term economic trends. • Correlation across the asset classes. • Potential of return relative to cash, risk and inflation. • Time horizons to filter short term noise in favour of long-term compounding. • We expect equities to be the main driver of returns within portfolios, preferring a small, focused portfolio. Other areas of focus are: Consistent return on investment capital. • Relatively stable top line and high gross margins. • Predictable and robust cash flows. • Strong balance sheets. • Good management of brands. • Generation of free cash flow. • Consistent dividend record. • We also consider the effects of frictional costs within portfolios such as dealing costs, management fees and taxation. The material risks of investing in our portfolios include: • Market Risk – Arises mainly from uncertainty about future prices of securities. It represents the potential loss the portfolio might suffer through holding market positions in the face of price movements. Evelyn Partners practitioners will manage market price risk on a daily basis in accordance with the investment objectives and mandate guidelines. • Inflation Risk – The value of your investment will be affected by inflation. Unless the performance of an investment meets or exceeds the rate of inflation, the real value of that investment will be reduced. • Interest Rate Risk – Interest rate risk represents the potential losses that the strategy may suffer due to adverse movements in relevant interest rates. The amount of income receivable from bank balances will be affected by fluctuations in interest rates. • Credit Risk – Credit risk is the risk that counterparties, or investment issuers will be unable or unwilling to meet a commitment that they have entered into and potentially result in financial loss. The strategy will be exposed to settlement risk on parties with whom it trades and custody risk. In managing this risk, Evelyn Partners seeks to work with and / or invest in institutions that are well known, financially sound and, where appropriate, well rated by rating agencies. Page 6  • Settlement Risk – Default by a broker could expose the strategy to an adverse price movement in the security between execution and settlement. When carrying out transactions in listed securities these are settled on cash versus delivery basis. • Currency Risk – Currency risk is the risk that the value of financial instruments will fluctuate due to changes in foreign exchange rates. Currency risk is addressed by the Investment Manager buying predominantly global businesses with a well-diversified currency profile. The currency exposure of cash holdings is actively managed on a regular basis. Note: All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends and other distributions), and the loss of future earnings. Although we manage the assets in a manner consistent with risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. There are also wider risks that may impact portfolios including: • Cybersecurity - Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from both intentional cyber-attacks and unintentional damage or interruption in service. A cybersecurity breach could expose the Firm, its clients, and their investments to substantial costs, civil liability, regulatory inquiry and/or action, compromised data, asset misappropriation, reputational harm, and operational disruptions. The adoption of internet- or cloud-based technologies and remote work environments may amplify these risks. In addition, as the Firm does not directly control the cybersecurity systems of third-party service providers, there can be no assurance that the cybersecurity practices of these providers will protect the Firm or its clients. • Public Health Emergencies and Pandemics - Pandemics and public health emergencies have the potential to materially impact economic activity in ways that are impossible to predict, all of which may result in significant losses to the Firm’s clients. In addition, governmental mitigation actions may constrain or alter existing financial, legal and regulatory frameworks in ways that are averse to the investment strategy of the Firm and client investment objectives. In addition, the operations of the Firm itself may be significantly impacted, or even temporarily halted, as a result of government quarantine measures, restrictions on travel and movement, remote-working requirements and other factors related to a public health emergency. Similar disruptions may occur in respect of the Firm’s service providers and counterparties, which could also negatively impact the clients. • Volatility Caused by World Events - World events such as terrorism, natural disasters, political and social turmoil, military conflicts (including the wars in Ukraine and the Middle East), as well as disruptions to global energy markets and international trade have resulted in substantial volatility in financial markets, impacting the wider global economy as well as directly impacted countries. Similar events and resulting fluctuations could have a substantial impact on the performance of investments in client accounts. • AI and Automated Technologies – The Firm may use machine learning, predictive data analytics, and similar automated decision-making technologies, including proprietary algorithms and models (collectively, “AI Technologies”), in connection with investment activities such as due diligence, predictive analysis, data interpretation, and operational functions. The use of AI Technologies involves significant risks, including potential inaccuracies, biases, cybersecurity threats, confidentiality concerns, and evolving legal and regulatory requirements, any of which could adversely affect the Firm or its clients. Additionally, AI Technologies may materially and adversely affect client investments by, among other things, contributing to the obsolescence of certain products, services, or business models in which a client is invested. AI Technologies and their applications continue to develop rapidly, and it is impossible to predict the full extent of current or future risks. There can be no assurance that the benefits of AI Technologies will justify the costs and expenses associated with their use. • Possibility of Fraud and Other Misconduct – Misconduct by employees, vendors, or service providers of the Firm or its clients could cause significant losses, including unauthorized transactions, failure to comply with operational or risk procedures, misrepresentations, misappropriation of assets, or improper use of confidential information. While the Firm maintains controls designed to minimize such risks, there can be no assurance that it will identify or prevent all misconduct, and the Firm may have limited remedies against responsible parties. • Dependence on Key Personnel – Investment performance depends in large part on the services, relationships, and expertise of the Firm’s key personnel, including its partners, directors, investment professionals, and other senior Page 7  management (collectively, “Key Persons”). If any Key Person were to become incapacitated or otherwise cease to be associated with the Firm, clients could experience material adverse effects, including disruption to investment activities and loss of institutional knowledge and relationships. There can be no assurance that Key Persons will continue to be associated with the Firm, or that the Firm would be able to attract and retain replacement personnel in a timely manner or at all. • Public Relations Risks – Negative media coverage, adverse publicity, or changes in public perception of the Firm, its personnel, or its investment strategies could negatively affect the Firm’s reputation and its ability to source investment opportunities, maintain relationships with counterparties and service providers, and retain or attract investors. Prediction markets and social media platforms may amplify reputational risks or expose the Firm to regulatory scrutiny, particularly if trading or speculation is perceived to be based on confidential or material, nonpublic information. 9. Disciplinary information The Firm has not been subject to any disciplinary action, whether criminal, civil or administrative (including regulatory) in any jurisdiction. Likewise, no person involved in the management of the Firm have been subject to such action. 10. Other financial industry activities and affiliations EPAM is not registered with FINRA and does not have any pending applications with any other broker-dealers or registered representative of broker-dealers outside of the Evelyn Partners Group. Our employees and management persons are not registered with the Commodity Futures Trading Commission (“CFTC”) and do not have any pending applications as a futures commissions merchant, commodity pool operator or commodity trading advisor. We are committed to providing clients with service of the highest quality and we are guided by the principle that we act in the best interests of our clients. Nevertheless, there are circumstances where client interests conflict with our interests or the interests of other clients. We have policies and procedures that are designed to ensure that we are always acting in the best interests of our clients. The Evelyn Partners Group has several “Regulated Entities”; however, it is only EPAM which is registered as an investment adviser with the SEC. Below is a list of Regulated Entities, including the authorization status and type of business for each. Type of Business Entity name Authorization status Broker-Dealer FCA Regulated Evelyn Partners Investment Services Limited Other Investment Adviser Evelyn Partners Securities FCA Regulated Other Investment Adviser FCA Regulated Evelyn Partners Investment Management LLP Other Investment Adviser FCA Regulated Evelyn Partners Investment Management Services Limited Other Investment Adviser SEC & FCA Regulated Evelyn Partners Asset Management Limited N/A Evelyn Partners Global IDF GP Limited Other Investment Adviser and sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Page 8  Other Investment Adviser FCA Regulated Evelyn Partners Discretionary Investment Management Limited FCA Regulated Other Investment Adviser Tilney Discretionary Portfolio Management Limited Dart Capital Limited FCA Regulated Other Investment Adviser Other Investment Adviser Evelyn Partners Investment Management (Europe) Limited Central Bank of Ireland (CBI) Regulated Other Investment Adviser Evelyn Partners International Limited Jersey Financial Services Commission (JFSC) Regulated FCA Regulated Other Investment Adviser Evelyn Partners Financial Planning Limited FCA Regulated Other Investment Adviser1 Evelyn Partners Financial Services Limited FCA Regulated Other Investment Adviser HFS Milbourne Financial Services Limited HW Financial Services Limited FCA Regulated Other Investment Adviser [Evelyn Partners Financial Planning Limited (“EPFP”) is not registered with the SEC as an investment adviser but has entered, or expects in the near future to enter, into a “participating affiliate” agreement with EPAM whereby certain of EPFP’s personnel provide various investment advisory services to EPAM for use with its U.S. clients. Any such EPFP personnel will be subject to EPAM’s compliance program, Code of Ethics, and supervision while providing services under the participating affiliate agreement. EPAM reserves the right to enter into new “participating affiliate” relationships with other of its affiliates or terminate its existing “participating affiliate” relationship with EPFP at any time.] In line with its corporate governance framework, the Evelyn Partners Board (the “Board”) maintains overall responsibility for the management of the Group, including ultimate oversight of Evelyn Partners Group Limited and its subsidiaries’ (including the Firm) operations. In addition the Board is responsible for ensuring that there is a competent and prudent management team; sound planning process; a strong and effective system of internal control; adequate accounting and other records; compliance with appropriate statutory regulatory obligations; a comprehensive set of management information to enable effective oversight, challenge and decision making; an embedded set of values and ethics; and a robust process for monitoring progress against strategic objectives and plans. The Firm is part of the Evelyn Partners Group. The Firm Board members are as follows: • Chris Grigg – Non-Executive Chairman and Chair of the Nominations Committee • Carla Stent – Independent Non-Executive Director and Chair of the Risk & Audit Committee • Chris Pell – Non-Executive Director (representing Permira Funds) Thibault Huysseune – Non-Executive Director (representing Permira Funds) • Peter Deming – Non-Executive Director (representing Warburg Pincus) • • Paul Geddes – Chief Executive Officer Evelyn Partners Group Limited and its solo-regulated subsidiaries • Kjersti Wiklund – Independent Non-Executive Director 1 Evelyn Partners Financial Services Limited has been sold, completion date is expected 1st April 2026. Page 9  Sally Boyle – Independent Non-Executive Director and Chair of the Remuneration Committee • • Alex Gersh - Chief Financial Officer Evelyn Partners Group Limited and its solo-regulated subsidiaries Sean Hagerty – Independent Non-Executive Director. • 11. Code of ethics, participation or interest in client transactions and personal trading The following is a summary of Evelyn Partners’ Code of Ethics and Personal Securities Transactions Policy (the “Code” or “Code of Ethics”) which has been adopted in accordance with Section 204A-1 of the Investment Advisers Act of 1940 (the “Advisers Act”) and to help ensure both the Firm and its employees comply with their fiduciary obligations to their client. A full copy of the Code is available to any client or prospective client upon request and without charge by contacting the Firm. The Firm’s Code of Ethics applies to access persons of the Firm and any other person the Chief Compliance Officer (“CCO”) deems appropriate (“Access Persons”). The foundation of the Code of Ethics is based on the underlying principles that: Employees must comply with relevant securities regulations. • Employees must at all times place the interests of the Firm’s clients first. • • Employees must make sure that all personal securities transactions are conducted consistently with the Code and Personal Account Dealing Policy. Employees must report any violation of the Code of Ethics. • Employees should not take advantage of their position at Evelyn Partners. • Evelyn Partners’ Access Persons are required to adhere to the Code of Ethics and certify their adherence to the Code upon commencing their employment and on an annual basis thereafter. Furthermore, all Access Persons are required to deliver to the CCO, or the delegated compliance function, a detailed report of personal transactions (covering substantially all securities other than exempted securities) undertaken during each calendar quarter. Information in respect of any new brokerage accounts opened during the relevant period is also required to be disclosed. Personal trading: From time to time, employees (and certain related persons) may have an interest in securities which are owned by clients of Evelyn Partners. In such circumstances, the Firm has policies in place to ensure that the interests of the Firm’s employees do not conflict with the obligations the Firm owes to its clients. All Access Persons must obtain pre-clearance from the CCO or a delegated compliance function for all personal trades in reportable securities and obtain pre-approval from the CCO, or the delegated compliance function, before engaging in any outside business activities or applying for an allocation of an Initial Public Offering (“IPO”) or private placement. Conflicts of interest- It is the policy of the Firm that all employees and others working on their behalf act in good faith and in the best interests of the Firm and its clients. The Firm has Policies and Procedures in place to identify and manage conflicts of interest. 12. Brokerage practices Evelyn Partners has full discretionary authority over the accounts of Clients (“Client Accounts”), including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. Evelyn Partners’ authority is limited by its own internal policies and procedures and investment guidelines. In selecting an appropriate broker-dealer to affect a client trade, Evelyn Partners seeks to obtain “best execution,” meaning that the Firm will execute a securities transaction for a client in such a manner that a client’s total costs or proceeds in the transaction are most favorable under the circumstances. Accordingly, in Page 10  seeking best execution, Evelyn Partners takes into consideration the price of a security offered by the broker- dealer, as well as a broker-dealers’ full range and quality of their services including, among other things, their facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to Evelyn Partners instructions and requests, brokerage and research services provided to Evelyn Partners (e.g., research ideas, analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. Aggregation of Orders - We may aggregate trade orders for the Client Accounts to achieve more efficient execution or to provide for equitable treatment among accounts. Client Accounts participating in aggregated trades will be allocated securities based on the average price achieved for such trades. Client Accounts will have an account with the relevant custodian. Soft Dollars - Evelyn Partners does not and has no intention to use “soft dollars” generated by our clients’ trading activities to purchase research services or products that would otherwise have been an expense of the Firm. Trade Errors - The Firm’s traders may on occasion experience errors with respect to trades made on behalf of the Client. Trade errors can result from a variety of situations, including for example, when the wrong security is purchased or sold, when the correct security is purchased or sold but for the wrong account, when the wrong amount is purchased or sold (e.g., 1,000 shares instead of 10,000 shares are traded), or when a misallocation among the Accounts occurs. The Firm endeavors to detect trade errors prior to settlement and correct them in an expeditious manner. 13. Review of accounts Each portfolio and Client Account that Evelyn Partners manages is subject to a review. These reviews are designed to ensure that all accounts remain within the Firm’s investment guidelines agreed with each client comparing the Clients Accounts performance to their stated goals. In addition, all clients will receive a periodic review where their situation and goals are discussed along with the performance of the portfolio. The client will receive statements regarding their account, its holdings, transactions and fees at least quarterly from the Firm and / or Pershing Securities Limited or Pershing Advisor Solutions LLC. 14. Client referrals and other compensation Evelyn Partners is not remunerated by any party other than its clients. The Firm does not currently utilize third party marketing firms for its U.S. clients. 15. Custody Advisers with custody of client funds and securities must maintain them with “Qualified Custodians.” “Qualified Custodians” under the amended rule include banks and savings associations and registered broker-dealers. Evelyn Partners does not maintain direct custody or possession of any of its Clients’ funds or securities. Clients’ funds and securities are held with qualified custodians. However, as client fees due to EPAM are deducted directly from our Clients’ accounts, EPAM is deemed to have sufficient custody and control of client assets pursuant to Rule 206(4)-2 of the Advisers Act. Evelyn Partners or the relevant custodian will at least quarterly send a client statement to the client as well as annually sending Privacy Notice and ADV Part 2. The principal place of business of EPAM is not in the United State and is thus not subject to Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) with respect to client accounts and funds that are not US persons (as defined in Regulation S under the Securities Act of 1933), as per ABA Subcommittee on Private Investment Entities, SEC Staff No-Action Letter (Aug. 10, 2006). Nevertheless, all client assets are physically held by third- party “qualified custodians” and the funds are subject to audit at least annually. Copies of audited financial statements are distributed to each of the relevant Fund’s respective investors no later than 120 days after the relevant Fund’s fiscal year end. Page 11  16. Investment discretion As set forth in the terms in the governing documents for each Client Account, EPAM has full discretionary authority to manage the discretionary Client Accounts, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. 17. Voting client securities Evelyn Partners will be notified of any action (which requires voting by the security holder) by the relevant Custodian. If Evelyn Partners exercise any vote on your behalf, we will always seek to vote in a manner that we determine to be in your best interests. We maintain written records of the proxy vote on each occasion a proxy is voted. Information on Evelyn Partners’ Proxy Voting Policy, including details of how the Firm has voted on a particular client proxy, is available upon request. Please refer to your Investment Manager. Where any material conflict is identified, the matter will be referred to the CCO for input on how best to proceed 18. Financial information Evelyn Partners has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of bankruptcy proceedings. Page 12